Response to COAH on Round 3 Proposed Regulations

I sent the following letter to COAH in response to the Round 3 proposed changes. It would be great if many citizens from Cranbury could send in comments to COAH as well . Responses can be sent to coahmail@dca.state.nj.us

Dear Ms.Voorhoeve,

I want to express my concern over the round three proposed regulations for COAH and the impact on the town of Cranbury. While affordable housing is a worthy goal, the new regulations will have a devastating effect on Cranbury which has diligently worked to fulfill its housing obligations.

Cranbury has been working well with COAH to meet and stay ahead of its affordable housing obligations. However, the new regulations are extremely punitive and it seems that Cranbury is being especially punished. The new regulations could require a one to one ratio of affordable homes for each existing home in Cranbury. The burden on the township would be tremendous in terms of new taxes necessary to support the housing and supporting services. I am sure you are getting flooded with messages from Cranbury. We had a township meeting which overflowed the room with almost 300 people (about 25% of the adult population). I want to point out a few issues:

• Making the rules retroactively effective back to 2004 is completely unfair. There are major new obligations based on commercial property already built or in progress. Making changes based on previously built property does not give the town the opportunity to assess appropriate fees to developers for affordable housing.
• The revised warehouse calculations for number of employees are completely inaccurate. There are far fewer employees in the warehouses than assumed in your new square footage calculation. In fact, the original ratios are also high.
• I don’t understand why there is a need to double the affordable housing inventory in the state. This is especially confusing in this economy.
• New Jersey is already very crowded and we don’t need to double the housing stock in our town. Growth needs to be managed carefully and these rules make development out of control. Small towns are a benefit to the state and we don’t need to turn the entire state into one overcrowded suburb.
• There will be a negative impact with these changes. The new regulations would require a massive tax increase and change in schools. This will chase a lot of people out of the town (and state) and depress property values. The depressed property values will require higher tax rates and make the affordable housing tax burden even more expensive.

I appreciate your attention to these concerns and sincerely hope you review the proposed regulations and change the obligations so that they will be closer to the previous regulations.